Judge Says Mandatory Injunctions Are Disfavored, But In The Case Of State Farm’s Handling Of PIP Claims The Situation Required One

In an order that was both direct and colorful, a judge of the Circuit Court of Hillsborough County, Florida, granted an Emergency Motion for Temporary Injunctive Relief in favor of Complete Care, a healthcare provider, and against State Farm for State Farm’s refusal to accept Personal Injury Protection (PIP) claims.

Florida requires drivers to carry PIP insurance, which State Farm issues. PIP insurance covers medical expenses and lost wages after an auto accident, regardless of fault. Complete Care provides personal injury healthcare services to auto accident patients and then bills State Farm. In April 2025, State Farm ceased accepting claims from Complete Care alleging that Complete Care was engaged in fraudulent submissions.

After a two-day evidentiary hearing, the court found that State Farm’s refusal to accept Complete Care’s PIP claims had no merit. In its order, the court stated, “And after two full focused days, what terrible, awful, scandalous acts did the evidence show that the fraudsters at Complete Care committed ? Did they double or triple bills? No. Did they charge wrong rates? No. Did they bill for services never rendered? No. Did they bill for services provided by unlicensed professionals? No. Oh my gosh…what could be more terrible…? The answer: ‘The delayed collecting of deductibles and co-insurance from their patients.’ Do scenes of people screaming and running from Godzilla flood your mind at this point? Really, you ask, “that’s all?’ Truly, ‘that’s all’.”

In addition to finding State Farm’s allegations meritless, the court found that the statute State Farm relied on in alleging fraud did not provide a platform to support a “delayed collection” cause of action. The court also noted that State Farm’s refusal to accept Complete Care’s PIP claims was, itself, a self-imposed mandatory injunction – one imposed without the assistance of the courts. The court also dismissed State Farm’s rebuttal that it had the right to impose the stoppage of Complete Care’s claims because it had a duty to “ferret out fraud.” The court stated that State Farm could not act as if it “[w]ere the Attorney General of the Insurance Universe.” Having found no sustainable cause of action and that irreparable harm was being done to Complete Care, the court granted the injunction requiring State Farm to once again accept and process Complete Care’s PIP claims.

The case is Complete Care Centers, LLC. v State Farm Automobile Ins. Co., et al, Case Nos. 25-CA-1063 and 25-CA-4520, Circuit Court of the Thirteenth Judicial Circuit In and For Hillsborough County, State of Florida, Civil Division, Oct. 21, 2025.